B-224054, MAR 17, 1987

B-224054, MAR 17, 1987

CIVILIAN PERSONNEL - TRAVEL - TRAVEL EXPENSES - DISCOUNTS - USE - REIMBURSEMENT DIGEST: AN EMPLOYEE, WHO TRAVELED ON OFFICIAL BUSINESS, CLAIMS REIMBURSEMENT FOR $50 DISCOUNT COUPON HE USED IN PURCHASING AIRLINE TICKET. THE DISCOUNT COUPON WAS EARNED BY THE EMPLOYEE IN CONNECTION WITH HIS PERSONAL, LONG- DISTANCE TELEPHONE CALLS. WE HOLD THAT THE EMPLOYEE MAY BE REIMBURSED ONLY FOR THE ACTUAL AND NECESSARILY INCURRED TRAVEL EXPENSES AND NOT FOR ANY GRATUITOUS PAYMENTS MADE IN THE COURSE OF OFFICIAL TRAVEL. PERSONALLY OBTAINED COUPONS SHOULD BE USED FOR PERSONAL PURPOSES ONLY AND NOT FOR OFFICIAL TRAVEL. THEREFORE, EMPLOYEE MAY NOT BE REIMBURSED FOR THE DISCOUNT COUPON.

PHILIP E. TRICKETT-- USE OF PERSONAL DISCOUNT COUPON FOR OFFICIAL TRAVEL:

THIS DECISION IS IN RESPONSE TO A CLAIM SUBMITTED BY MR. PHILLIP E. TRICKETT, AN EMPLOYEE OF THE DEPARTMENT OF THE AIR FORCE, FOR REIMBURSEMENT OF THE VALUE OF A PERSONALLY-OBTAINED DISCOUNT COUPON HE USED IN CONNECTION WITH OFFICIAL TRAVEL. FOR THE REASONS SET FORTH BELOW, WE HOLD THAT MR. TRICKETT MAY NOT BE REIMBURSED FOR THE AMOUNT HE ALLEGES TO BE THE VALUE OF THE DISCOUNT COUPON.

MR. TRICKETT WAS AUTHORIZED TO TRAVEL FROM HIS PERMANENT DUTY STATION AT WRIGHT-PATTERSON AIR FORCE BASE, OHIO, TO THE NAVAL AIR STATION IN LEMOORE, CALIFORNIA, FOR TEMPORARY DUTY IN NOVEMBER 1985. HE STATES THAT AFTER MAKING HIS AIRLINE RESERVATIONS THROUGH THE SCHEDULED AIRLINE TICKET OFFICE (SATO), HE CHOSE TO PURCHASE HIS ROUND TRIP TICKET AT THE AIRPORT TICKET COUNTER USING HIS PERSONAL CREDIT CARD. HE FURTHER STATES THAT THE COST OF THE TICKET ($522) WAS THE SAME WHETHER HE OR THE GOVERNMENT PURCHASED THE TICKET.

WHEN MR. TRICKETT PURCHASED THE ROUND-TRIP AIRLINE TICKET, HE ALSO USED AN AMERICAN TELEPHONE AND TELEGRAPH (AT&T) TRAVEL CERTIFICATE WHICH HE HAD EARNED THROUGH PERSONAL LONG-DISTANCE TELEPHONE CALLS OVER AT&T LONG- DISTANCE LINES.

BY USING THIS CERTIFICATE HE RECEIVED A $50 CREDIT TOWARDS THE PURCHASE OF THE AIRLINE TICKET. THE AIR FORCE LATER REIMBURSED MR. TRICKETT ONLY FOR HIS ACTUAL COST OF TRAVEL ($472) AND DENIED HIS CLAIM FOR THE ADDITIONAL $50 REPRESENTING THE REDUCTION IN THE COST OF THE TICKET THROUGH THE USE OF THE DISCOUNT COUPON. THE AGENCY REPORT STATES THAT THESE SAVING CERTIFICATES CANNOT BE REDEEMED FOR CASH BUT MAY BE USED ONLY TO REDUCE THE PRICE OF A PRODUCT OR SERVICE OBTAINED BY THE INDIVIDUAL. THE AGENCY REPORT RECOMMENDS DENIAL FOR THE CLAIM ON THE BASIS THAT REIMBURSING THE TRAVELER FOR THE VALUE OF THE CERTIFICATE WOULD CONVERT THE CERTIFICATE INTO CASH.

MR. TRICKETT ARGUES THAT THE CERTIFICATE WAS WORTH $50 TO HIM, THAT HE EARNED THE CERTIFICATE THROUGH PERSONAL, LONG-DISTANCE TELEPHONE CALLS MADE AT HIS EXPENSE, AND THAT THE GOVERNMENT SHOULD NOT CLAIM ALL OF THE BENEFITS THROUGH HIS USE OF HIS PERSONAL CERTIFICATE. IN AN EMPLOYEE SUGGESTION HE SUBMITTED TO THE AIR FORCE, MR. TRICKETT RECOMMENDS THAT EMPLOYEES RECEIVE 80 PERCENT OF THE SAVINGS ACHIEVED BY USE OF THESE CERTIFICATES WHICH WOULD ACT AS AN INCENTIVE TO EMPLOYEES TO USE THE CERTIFICATES AND WOULD BENEFIT THE GOVERNMENT BY REDUCING THE COST OF TRAVEL.

OPINION

NEITHER THE STATUTES NOR THE APPLICABLE REGULATIONS GOVERNING THE TRAVEL OF FEDERAL EMPLOYEES SPECIFICALLY PROVIDE FOR THE REIMBURSEMENT TO EMPLOYEES OF THE VALUE OF CERTIFICATES SUCH AT THOSE USED BY MR. TRICKETT. SEE 5 U.S.C. SEC. 5706 (1982) AND PARAGRAPH 1-2.1 OF THE FEDERAL TRAVEL REGULATIONS, FPMR 101-7 (SUPP. 5, JUNE 19, 1983), INCORP. BY REF., 41 C.F.R. SEC. 101-7.003 (1985), WHICH AUTHORIZE THE REIMBURSEMENT OF ONLY THE ACTUAL AND NECESSARY TRAVEL EXPENSES INCURRED BY AN EMPLOYEE. IN AN ANALOGOUS SITUATION WE CONSIDERED THE CLAIM OF AN EMPLOYEE WHO TRAVELED ON OFFICIAL BUSINESS USING A FREE AIRLINE TICKET ISSUED TO HER HUSBAND THROUGH HIS MEMBERSHIP IN AN AIRLINE FREQUENT FLYER PROGRAM. WE HELD IN MARTHA C. BIERNASKI, 65 COMP.GEN. 171 (1985), THAT THE EMPLOYEE COULD NOT BE REIMBURSED THE CONSTRUCTIVE COST OF THE TICKET IN THE ABSENCE OF ANY LEGAL OBLIGATION ON HER PART TO PAY FOR THIS FREE TICKET.

ALTHOUGH WE RECOGNIZE THAT IT IS POSSIBLE TO PLACE A "VALUE" ON A TRAVEL CERTIFICATE, BONUS COUPON, OR SIMILAR INSTRUMENT OBTAINED THROUGH AN EMPLOYEE'S INDEPENDENT, PERSONAL ACTIONS, WE DO NOT BELIEVE THAT IT IS IN THE GOVERNMENT'S INTEREST TO BECOME INVOLVED IN THE USE OF SUCH INSTRUMENTS. TO ALLOW REIMBURSEMENT TO AN EMPLOYEE WHO HAS USED PERSONALLY OBTAINED DISCOUNT COUPONS COMPOUNDS THE PROBLEMS OF CONTROL AND ACCOUNTABILITY. IN OUR VIEW, THE BEST WAY TO SIMPLIFY THESE MATTERS IS TO DENY REIMBURSEMENT TO AN EMPLOYEE FOR THE USE OF PERSONALLY OBTAINED DISCOUNT COUPONS AND TO CHARGE THE EMPLOYEE FOR THE VALUE OF THE USE OF DISCOUNT COUPONS OBTAINED DURING GOVERNMENT TRAVEL. SIMPLY PUT, GOVERNMENT COUPONS SHOULD BE USED FOR GOVERNMENT PURPOSES ONLY AND PERSONAL COUPONS SHOULD BE USED FOR PERSONAL PURPOSES ONLY, TO INSURE THE GREATEST DEGREE OF ACCOUNTABILITY AND CONTROL.

THEREFORE, WE CONCLUDE THAT MR. TRICKETT MAY BE REIMBURSED ONLY FOR HIS ACTUAL COSTS INCURRED IN HIS AIRLINE FLIGHT, NAMELY $472.